ID: nht68-3.12

DATE: 01/26/68

FROM: AUTHOR UNAVAILABLE; Roger H. Compton: NHTSA

TO: Fire Department, Lynn, Massachusetts

TITLE: FMVSS INTERPRETATION

TEXT: In your letter of December 12, 1967, you questioned several requirements of Initial Motor Vehicle Safety Standard No. 108 as applied to fire trucks.

Paragraph S3.1.1.3, which permits the installation of additional equipment if it does not impair the effectiveness of the required equipment, will not prohibit the installation of rotary flashing lights on fire trucks. Therefore, a waiver of this clause is not necessary for fire trucks.

Paragraph S3.5 a revised by the latest amendment to Standard No. 108, and issued December 11, 1967, (copy enclosed), permits the flashing of steady-burning lamps for signalling purposes. Therefore, the flashing of side marker and clearance lamps on fire trucks to signify an emergency vehicle will not be prohibited by the requirements of this paragraph.

Standard No. 108 does not require that front identification lamps be located on the roof of the vehicle cab, but only that they be "as near as practicable to(Illegible Word) vertical centerlines." If, however, they are mounted on the upper body structure, "no part of the lamps or mountings may extend below the top of the vehicle's windshield." This mounting flexibility will permit a selective location of identification lamps and rotary warning lamps which will not cause the rotary lamps to blot out the identification lamps. Also to be considered is the effectiveness of the identification lamps when the vehicle is operated on the highway and without illumination of the rotary lamps. Therefore, fire trucks need not be excepted from the requirement for front identification lamps.

Rear identification lamps mounted on the edge of or under the rear step of a fire truck will meet the location requirements as specified in Standard No. 108. Adequate guards or protective shields are available and commonly used on lamps located in these positions. Therefore, fire trucks need not be excepted from the requirement for rear identification lamps.

If you have any further comments or questions on the requirements of Standard No. 108, I hope you will let us know.

ID: nht68-3.13

DATE: 02/09/68

FROM: AUTHOR UNAVAILABLE; Joseph R. O'Gorman; NHTSA

TO: Electrographic Corporation

TITLE: FMVSS INTERPRETATION

TEXT: In your letter of December 18, 1967, to Mr. Lowell K. Bridwell, you describe the procedure initiated by you for identifying and marking light hit containers. You ask for our acknowledgement of the procedure. It is not clear from your letter, but we gather that you manufacture truck bodies and ship light kits in a separate box, either to accompany or separate from the truck bodies.

The so-called "lighting Standard," Standard 103 of the initial Federal Motor Vehicle Safety Standards, to entitled "Lamps, Reflective Devices, and Associated Equipment." The standard applies to multipurpose passenger vehicles, trucks, trailers and buses, that are 80 or more inches wide overall, except pole trailers and converter dollies. It is the manufacturer of the completed vehicle who must certify that the vehicle conforms to all applicable Federal motor vehicle safety standards, including Standard No. 103. Unless the manufacturer of the lighting equipment and the completed vehicle are the same, the manufacturer of lighting equipment is not required to certify that such equipment conforms to Standard No. 103. It would seem logical to expect that the manufacturer of the completed vehicle would require from the manufacturer of the lighting equipment some indication that the lighting equipment is in conformity, but that is a matter to be settled between the two persons involved. Thus, while we have no objection to the procedure described in your letter, we do wish to emphasize that it does not relieve the vehicle manufacturer of insuring compliance and certifying to such compliance where appropriate.

Thank you for your interest. If further information is needed, please feel free to contact this office.

ID: nht68-3.14

DATE: 05/24/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Department of California Highway Patrol

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of April 5, 1968, (Reference 61.A218.A1115) addressed to Dr. William Haddon, Jr., concerning the location of clearance lamps on several styles of truck bodies manufactured by the Utility Body Company.

Rear clearance lamps mounted at the top corners of the sleeper cab of the vehicle in Figure 1 of the drawing attached to your letter would not be in conformance with the requirements of Federal Motor Vehicle Safety Standard No. 108. On this same vehicle, the required location of the front clearance lamps is at the top corners of the sleeper cab. The additional set of front clearance lamps on the truck cab would not be required or prohibited by Standard No. 103. Locations of rear clearance lamps on the vehicles shown in Figure 2 and Figure 3 of the drawing are in accordance with the requirements of Standard No. 108.

Our records do not indicate that we have furnished any evidence to the Utility Body Company regarding location of rear clearance lamps as shown in Figure 1. Under their letter of March 11, 1968, this company submitted to us a print of their drawing, which is identical to the drawing enclosed with your letter, and requested our comments on the proposed locations of their lighting equipment. The above information will be furnished to the Utility Body Company in reply to their March 11 letter and should serve as clarification of the requirements of Standard No. 108. This clarification also indicates that no conflict exists between the requirements of Standard No. 108 and the requirements of the California Vehicle Code with respect to location of your clearance lamps.

ID: nht68-3.15

DATE: 05/15/68

FROM: AUTHOR UNAVAILABLE; William Hadden, Jr.; NHTSA

TO: Mercedes Benz of America, Incorporated

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your telegram of May 3, 1968, concerning the use of tabular-type bulbs to back the requirements of Federal Motor Vehicle Safety Standard No. 108.

Paragraph S3.1 and Tables I and III of Standard No. 108, as amended (32 F.D. 13933, December 10, 1967), specify that certain lamp assemblies such as license plate lamps, backup lamps and tail lamps, shall conform to the basic SAE Standards for the lamp assemblies. These basic standards in turn refer to SAE Standard 7573 on bulbs and to SAE Standard 3567 on bulb sockets. This relationship between the basically referenced standards and subreferenced standards has been the subject of prior communications with the industry and appears to be in need of clarification.

The basically referenced SAE Standards also refer to SAE Standard J575, "Test for Motor Vehicle Lighting Devices and Components." Paragraph "C" of SAE Standard J575 states in part as follows: "Where special bulbs are specified, they should be submitted with the devices and the same or similar bulbs used in the tests and operated at their rated mean epherical candlepower." This provision of SAE Standard J575 permits the use of special bulbs, including tubular-type bulbs, which do not conform to the detailed requirements of Table I of SAE Standard J573. It also follows that the sockets for these special bulbs need not conform to SAE Standard J567. I must emphasize, however, that these provisions for special bulbs in no way except the lamp assemblies from testing all performance requirements specified in Standard No. 108, including those specified in the basically referenced SAE Standards and in subreferences SAE Standard J575.

In view of the several inquiries we have resolved on this particular(Illegible Word) of the requirements of Standard No. 108, we anticipate that an official interpretation, providing the clarification presented in this letter, will be published in the Federal Register in the near future.

Thank you for your continued interest in the Federal Motor Vehicle Safety Standards.

ID: nht68-3.16

DATE: 02/07/68

FROM: AUTHOR UNAVAILABLE; Joseph R. O'Gorman; NHTSA

TO: American Quality Coach Corporation

TITLE: FMVSR INTERPRETATION

TEXT: Thank you for your letter of January 8, 1968, to the Federal Highway Administration, requesting regulations relating to motor vehicle safety requirements.

The type of vehicle that you have described appears to be a bus accordingly to the statutory meaning of Part 255.3, Initial Federal Motor Vehicle Safety Standards. Accordingly, Standards 102, 107, 205 and 209 would be applicable to your vehicles manufactured after January 1, 1968. We invite your attention to Section 114 of Public Law 89-563 and the notice of Certification Requirement.

In addition to the existing Federal Motor Vehicle Safety Standards and Public Law 89-563, we are enclosing information concerning proposed rule making that may affect future regulations.

We trust this information will be of assistance to you.

ID: nht68-3.17

DATE: 03/02/68

FROM: AUTHOR UNAVAILABLE; Joseph R. O'Gorman; NHTSA

TO: Field Body Company Inc.

TITLE: FMVSR INTERPRETATION

TEXT: Thank you for your letter of January 8, 1968, in regard to certification of your product and questions regarding interpretation of the Chassis-Cab regulation.

In regard to your letter furnishing us certification information, what you have provided will be very useful to us; however, in accordance with Section 112 of the National Traffic and Motor Vehicle Safety Act of 1966, it would be appreciated if you would provide us with an actual sample of your certification label and the method of attachment.

Concerning your request for clarification in regard to the extent of responsibility for adherence to applicable safety standards to your type of vehicle, the following should be of assistance:

First, your vehicle, completed, falls into the category defined as a "truck" and as such, must adhere to Safety Standards 102, 107, 108, 205 and 209. We have enclosed a copy of the Federal Register, Volume 32, No. 23, dated February 3, 1967, and several other pertinent amendments.

Regarding extent of responsibility of the chassis-cab body manufacturer, and final assembler of the units into a completed vehicle, these are clarified in Section 2 you refer to in your letter. I assume this is Federal Register Volume 33, No. 1, dated January 3, 1968, "Notice of Ruling regarding Chassis-Cabs," but in case it is not I am enclosing a copy for your reference. This notice defines two main points which I will endeavor to state in a few words as follows:

If the original manufacturer of the chassis, after January 1, 1968, cannot or does not include all the safety standard regulations required for the type of end product or completed assemblage, then the final assembler is responsible to certify that all applicable safety standards are included and the vehicle is so certified and labeled.

Thank you for your interest in the safety program.

ID: nht68-3.18

DATE: 03/12/68

FROM: AUTHOR UNAVAILABLE; Joseph R. O'Gorman; NHTSA

TO: The Reuben H. Donnelley Corporation

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of February 27, 1968, to the Federal Righway Safety Bureau, in regard to obtaining information about Safety Standard No. 209, seat belt assemblies.

Regarding your question on seat belt usage as pertaining to a fire apparatus vehicle, seat belts are not required to be installed, however, if seat belts are installed on a truck by a manufacturer, the seat belt assemblies, as equipment, must meet the requirements of Standard 209, specifically, requirements of the Department of Commerce, National Bureau of Standards for seat belts for use in motor vehicles (15 CFR 9)(30 FR 8432).

Thank you again for your interest in the safety program.

ID: nht68-3.19

DATE: 03/25/68

FROM: AUTHOR UNAVAILABLE; William Haddon, Jr., M.D.; NHTSA

TO: Renault

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of December 1, 1967, concerning tests made on the Renault 10 model for compliance with Federal Motor Vehicle Safety Standard No. 203.

We recognise the validity of a system which takes advantage of the energy absorbing characteristics of the surrounding vehicle structure as on alternative to the more conventional approach of employing on energy absorbing column and/or wheel. As you mentioned, SAE J944 was not written with that type of energy absorbing system in mind. The structure which you intend to employ to provide the energy absorbing requirements specified in Federal Motor Vehicle Safety Standard No. 203 might in reality first be severely stressed and deformed in a crash eltuation. Therefore any laboratory test used to evaluate such a system should recognize this detrimental influence. In the event that you would wish to submit a proposed alternative test procedure which incorporates a barrier test is specified in Standard No. 204 prior to testing for compliance with Standard No. 203, we would be pleased to consider such a request.

Your second point concerns the need for a more explicit definition of translational motion. SAE J944 states that the body-block contacts the wheel in translational motion. It does not say that this motion must continue after impacting the wheel. Your magnetic release mechanism appears to impart approximately translational motion to the body-block at impact and is a satisfactory procedure. The fact that the body-block is free to rotate forward after impact is a stimulation of an actual crash situation and the body-block was not intended by SAE J944 to be restrained in translational motion after impact. Since the body motion in on actual crash situation will very somewhat the Bureau feels that a more explicity definition of translational motion is unnecessary.

The third series of tests as described in Report No. 287.397 using a right test fixture and the free flying body-block are compatible with the SAE J944 test procedure.

Your interest in motor vehicle safety is appreciated.

ID: nht68-3.2

DATE: 02/20/68

FROM: AUTHOR UNAVAILABLE; H.M. Jacklin, Jr; NHTSA

TO: Toyo Kogyo Company, Limited

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of November 30, 1968 (your reference No. CSAI-25) requesting information to a number of questions related to the Federal Motor Vehicle Safety Standard. I(Illegible Word) that we did not receive your October 5, 1968 letter and that the(Illegible Word) of work has delayed my answer to your most recent letter.

I am glad to send you the following information:

a.(Illegible Word) No. 112 - Headlight Concealment Devices.

1. It is stipulated in 3.4.5 that "each headlamp concealment device shall, within an ambient temperature range of -70 to +120 degrees F., be capable of being fully opened in not(Illegible Line) described in S.4.3." With regard to the temperature condition at the time of a test, if only the(Illegible Word) temperature satisfied the cold temperature conditions, is it all right to try no regard to other conditions, such as the sticking of frost, ice, etc.?

ANSWER: It is only necessary that the ambient temperature conditions (-20 to +120 degrees F.) be(Illegible Word) at the time of the test.

b.(Illegible Word) No. 114 - Thoft Protection.

1. With regard to the regulation in s.4.2 that "The prime cause for deactivating the csr's engine or other main source of motive power shall not activate the(Illegible Word) required by S4.11(b)," we have provided the ignition switch with four stages as shown in the batch below; our key-locking system is of the(Illegible Word) that the system does not activate(Illegible Line)(Illegible Line)

ANSWER: The system as you describe it appears to conform to(Illegible Line)(Illegible Line) with this requirement to the responsibility of the individual manufacturer.

2. With reference to the stipulation in S.4.1. "Each passenger car shall have a key-locking system that, whenever the key is removed, will prevent ----.", we would like to know whether or not we must provide such a mechanism as the key can be removed only at the stage "Lock" and cannot at the stage "Off".

ANSWER: A locking system having such a position that the key may be removed without activating either the cars' steering lock or its self-mobility lock would not conform to the standard in its present form, since paragraph S4.1 of the standard requires each car to have a key locking system that, whenever the key is removed, will prevent either steering or self-mobility of the car, or both.

c. MVSS No. 201 - Occupant Protection in Interior Impact 1. With regard to the interpretation of the stipulation in S.3.1 " , the deceleration of the head form shall not exceed 80 g for more than 3 milliseconds," when the deceleration wave -- shown in the chart below -- is obtained.

in case DELTA t[1] < 3 milliseconds, we interpret that the standard is satisfied even when delta t[1] +="Sigma" t[2] t[3] t[i] milliseconds.

Is our interpretation correct? (Illustration omitted)

ANSWER: Your interpretation is correct. The standard permits more than one peak that exceed 80g which, cumulatively, may add to more than 3 milliseconds. No single peak may continuously exceed 80g for more than a 3 millisecond duration.

2. When the areas stipulated in S.3.1.1.(d) -- "Areas outboard of any point of tangency on the instrument panel of a 6.5 inch diameter head form tangent to an inboard of vertical longitudinal plane tangent to the inboard edge of the steering wheel," -- are illustrated, which of the following hatched portions in the figures below is in conformity to the stipulation? (Illustration omitted)

ANSWER: Figure (a) is correct for the inboard side. Present requirements do not apply to the area outboard of the steering wheel on the instrument panel.

d. MVSS No. 207 - Anchorage of Seats.

S.3.3 Folding and hinged seats. Except for folding auxiliary seats and seats with backs which are adjustable for occupant confort only.

1. Is it correct to interpret that the underlined part is referring to seats with backs reclining mechanism enabling to adjust the angle of the back?

ANSWER: Yes.

2. Or, should we interpret that the seats with reclinable backs come under the hinged seats?

ANSWER: No.

3. a. In the case of car with four doors, if the front seats are those with reclinable backs, these are presumed to be the ones corresponding to (1). Is this interpretation correct?

ANSWER: Yes.

b. In the case of a car with two doors, we would like to interpret that only the reclinable seat backs with folding mechanism enabling the passenger on the rear seat to get in and out are in conformity to (2). Is our interpretation correct?

ANSWER: Yes.

S.3.3.1 The release control shall be readily accessible to the occupant of that seat and to the occupant of any seat immediately behind that seat.

1. The above stipulation is presumed to be laid down for the egress of the passengers on the rear seat. Therefore, when the reclining seats are installed in a four-door car, we would like to consider it unncessary to pay regard to the underlined part. Is this interpretation correct?

ANSWER: Yes.

2. In the case of a two-door car, if the control which can be easily operated by passengers on the rear seat is installed only on one side (the right side), the passengers on the rear seat can operate the control by moving to the right side. Consequently, we consider it sufficient to install only on the right side the control which is easily accessible to the passengers on the rear seat. Is this interpretation correct?

ANSWER: In the case of a two-door car, for a split back or bucket seat arrangement, where both seat backs fold, a release control should be provided on the outboard side of each folding seat back. If the seat back is split and only one seat back folds, only one release control is required on the outboard side.

e. MVSS No. 210 - Seat Belt Assembly Anchorages

1. We judge that the fastening strength of the seat belt anchorage will change, depending on the shape of the eye bolt attaching the seat belt to the seat belt anchorage point.

If an anchorage is tested by using our designed seat belt assembly and the strength of the anchorage can be assured, we understand that the anchorage fully conforms to the standard, and also understand that it is not necessary to guarantee the owners of Mazda vehicles if they attach a seat belt assembly other than the one designated by us. Is our interpretation correct?

We, of course, will specify in our Operation Manual that the seat belt assembly designated by our company must be used.

ANSWER: Under Paragraph S.5.1 of Federal Motor Vehicle Safety Standard No. 210, anchorages are to be tested by using a Type 1 or Type 2 seat belt assembly as defined in FMVSS No. 209. If you follow this procedure, using a belt which complies to No. 209, and your anchorages meet the requirements of Standard No. 210, then you are in compliance with this standard.

I must point out that this Bureau does not issue approvals on items of equipment or on vehicle designs. Therefore, the above comments are for your information only and in no way relieve the vehicle manufacturer from his responsibility for certifying that the assembled vehicle meets the requirements of the Standards.

ID: nht68-3.20

DATE: 02/03/68

FROM: AUTHOR UNAVAILABLE; Alan S. Boyd; NHTSA

TO: John E. Moss; House of Representatives

TITLE: FMVSR INTERPRETATION

TEXT: Thank you for your letter of November 30 regarding the Notice of Proposed Rule Making published that day in the Federal Register relative to the promulgation by the Department of the Treasury and the Department of Transportation of regulations governing the importation of motor vehicles and equipment manufactured after December 31, 1967.

You have asked the statutory authority for "six proposed exemptions" set forth in proposed 19 C.F.R. Sec. 12.80(b). You will see from the enclosed copy of the final regulations published on January 10 that there are now seven exceptions in 19 C.F.R. Sec. 12.80(b). However, there are exceptions only from the requirement of paragraph (b) that a vehicle(Illegible Word) valid certification as a condition of entry into the United States. They are not exemptions from compliance with the Federal motor vehicle safety standards where compliance is required by the National Traffic and Motor Vehicle Safety Act of 1966. With specific reference to each of the seven exceptions to vehicle certification provided by 19 C.F.R. Sec. 12.80(b):

"(i) Such vehicle or equipment item was manufactured on a date when there were no applicable safety standards in force, a verbal declaration being acceptable at the option of the district director of customs for vehicles entering at the Canadian and Mexican borders;"

Section D8(a)(1) of the Act prohibits importation of a motor vehicle manufactured on or after the date any applicable safety standard is in effect unless the vehicle is in conformity with such standard. This section makes it clear to customs officer and the public that vehicles manufactured prior to the effective date of a standard need not comply with the standard in order to be imported.

"(ii) Such vehicle on equipment item was not manufactured in conformity with applicable standards but has since been brought into conformity, such declaration to be accompanied by the certificate of the manufacturer, contractor, or other person who has brought such vehicle or equipment item into conformity which described the nature and extent of the work performed;"

No exemption from compliance is allowed and it is assumed from the statement of the responsible contractor submitted concurrent with the declaration that the vehicle fully conforms with the requirements of section 108(a)(1) at the time of its admission into the United States.

"(iii) Such vehicle or equipment item does not conform with applicable standards, but that the importer or consiance will bring such vehicle or equipment item into conformity with such standards;"

This temporary exemption is permitted by section 108(b)(3) of the Act which provides that nonconformity vehicles may be admitted upon terms and conditions sufficient to insure they are brought into conformity.

"(iv) Such vehicle is a new vehicle being imported for purposes of resale which does not presently conform to all applicable safety standards because readily attachable equipment items are not attached, but that there is affixed to its windshield a label stating the standard with which and the manner in which such vehicles does not conform and that the vehicle will be brought into conformity by attachment of such equipment items before it will be offered for sale to the first purchaser for purposes other than resale;"

Comments submitted by several European motor vehicle manufacturers in response to the Notice of November 30 indicated that exterior equipment items such as rearview mirrors and wheel covers, which are subject to breakage or theft, are commonly shipped separately from new motor vehicles. Additionally, one foreign manufacturer expressed its preference for utilization of American made passenger restraint systems and consequent installation of such systems after arrival of its vehicles in the United States. Since it is only in minor ways that the vehicles in the United States, the offer for sale of a nonconforming vehicle would be a violation of section 108(a)(1) of the Act, it seems appropriate to allow entry of there vehicles with an informational label stating the fact of nonconformance and that the vehicle will be brought into conformance before being offered for sale at the retail level.

"(v) The importer or consignee is a nonresident of the United States, importing such vehicle or equipment item primarily for personal use or for the purpose of making repairs or alterations to the vehicle or equipment item, for a period not exceeding 1 year from the date of entry, and that he will not resell it in the United States during that time; Provided, That person regularly entering the United States by a motor vehicle at the Canadian and Mexican borders may apply to the district director of custom for an appropriate means of identification to be affixed to such vehicle which will serve in place of the declaration required by this paragraph;"

"(vi) The importer or consignee is a member of the armed forces of a foreign country on assignment in the United States, or is a member of the Secretariat of a public international organization so designated pursuant to 59 Stat. 669 on assignment in the United States, or is a member of the personnel of a foreign government on assignment in the United States who comes within the class of persons for whom free entry of motor vehicles has been authorized by the Department of State and that he is importing such vehicle or equipment item for purposes other than resale;"

These exemptions are permitted by section 108(b)(4) of the Act which permit "temporary importation" of noncomplying motor vehicles. The Department of State informally advised that any interpretation of "temporary" as meaning a period of less than "one year" might not be in accordance with several international road and traffic Conventions to which the United States is a party. The Canadian-Mexican provision in item (v) is designed to facilitate entry and exit of vehicles owned by nationals of these countries who are employed in the United States, and who commute regularly to and from their jobs across the border.

"(vii) The importer or consignee is importing such vehicle or equipment item solely for the purposes of show, test, experiment, competition, repairs, or alterations and that such vehicle or equipment item will not be sold or licensed for use on the public roads." This is not an exemption permitted by section 108(b) but an exemption granted on the basis that experimental, show, test, or competition vehicles have not been built "primarily for use on the public roads" and hence are not "motor vehicles" (within the definition of section 102(2) of the Act) subject to regulation by the Secretary.

I hope this will answer your questions.